PulseDNA Coach Privacy Policy
Effective date: 27 October 2026
PulseDNA Coach turns your Apple Health data into a daily readiness score and coaching plan. We built it so your health data stays on your devices. This policy explains what the app handles, why, who else is involved, and the choices you have.
1. Who we are
PulseDNA Coach is made by AdeptLabs. Adept Labs Technology Company Limited, Phu Tho Province, Vietnam, is the "controller" of the personal data described here.
- Contact: admin@adept-labs.com
- Data protection officer: we have not appointed a DPO because we are not required to.
2. The short version
- Your health data (steps, sleep, heart rate, HRV and similar) is read from Apple Health on your device and processed there. It is never sent to us or to any third party.
- Readiness scores, AI coaching, sleep, movement and heart predictions are computed on your device with Apple's on-device technologies.
- We receive usage statistics and crash reports through Google Firebase. They never contain health data or anything computed from it.
- No ads, no tracking across apps, no selling or sharing of personal data.
3. What the app handles and why
3.1 Health data (stays on your device)
With your permission, the app reads these Apple Health types: steps, active energy, sleep analysis, heart rate, resting heart rate and heart rate variability (HRV). The Apple Watch app can save breathing sessions to Apple Health as mindful minutes if you allow it. The iPhone app does not write to Apple Health.
| Data | Where it lives |
|---|---|
| Health data read from Apple Health | Processed on your iPhone and Apple Watch. Not uploaded anywhere. |
| Readiness scores, insights, missions, journal entries, plans and history | A database on your device and the app's shared storage for widgets and Apple Watch |
| AI Coach conversations | On your device only |
| Settings and preferences | On your device |
Health data is used only to provide the app's wellness features. It is never used for advertising or marketing, never sold, and never shared with third parties, as required by Apple's HealthKit rules. You can grant or revoke Health access at any time in the Health app or in iOS Settings › Health › Data Access & Devices.
3.2 On-device AI
AI Coach (on supported devices with Apple Intelligence), readiness scoring and the sleep, movement and heart models run on your device using Apple Foundation Models and Core ML. Your data is not sent to us or to any AI provider. AI Coach responses are informational and are not medical advice.
3.3 Usage statistics and crash reports (Google Firebase)
What:
- Which screens and features are used, for example "mission completed" or "paywall viewed".
- Simple counts and settings, for example the number of missions or whether notifications are on.
- Which subscription product was chosen and whether the purchase went through.
- Crash reports and error reports: technical state when something goes wrong.
- Device and app information: model, OS version, language, app version.
- Random app identifiers: a Firebase app-instance ID and a Crashlytics installation ID.
- An approximate region, which Google derives from your IP address.
What we never put in them: health data from Apple Health, readiness scores or anything else computed from your health data, journal text, AI Coach conversations, your name or contact details.
We don't use the advertising identifier (IDFA) and we don't track you across other companies' apps or websites.
Why: to find and fix bugs and crashes, and to understand which features are useful.
3.4 Subscriptions
PulseDNA Pro is sold through Apple's App Store. Apple processes your payment; we never see your payment details. The app receives a record of your purchase from Apple (StoreKit) to unlock Pro features and to restore purchases.
3.5 Support
If you email us, we use your email address and message to reply and to keep a record of the request.
3.6 Device permissions
The app asks before using Apple Health and notifications. Widgets, Live Activities, Siri, Shortcuts, Spotlight and Apple Watch features work on your devices.
4. Legal bases (EU/EEA and UK)
| Purpose | Legal basis |
|---|---|
| Health features on your device (3.1, 3.2) | Your explicit consent, given through Apple Health permissions (Art. 9(2)(a) GDPR). We do not receive this data. |
| Usage statistics and crash reports (3.3) | Legitimate interests (Art. 6(1)(f)): keeping the app reliable and improving it. You can object (section 8). |
| Subscriptions (3.4), support replies (3.5) | Contract (Art. 6(1)(b)), and legal obligation where records must be kept (Art. 6(1)(c)) |
5. Who processes data for us
| Provider | What they do | Data |
|---|---|---|
| Apple Inc. / Apple Distribution International | App Store payments and subscriptions, Apple Health, on-device AI. Apple acts under its own terms and privacy policy. | Purchase data |
| Google LLC / Google Ireland Ltd (Firebase Analytics, Crashlytics) | Our processor, under Google's data processing terms | 3.3 |
We do not sell personal data or share it for cross-context behavioural advertising. We may disclose data if the law requires it, to protect people's safety, or as part of a business transfer under this policy.
6. International transfers
Google may process data in the United States and other countries. Where data leaves the EU/EEA, the UK or Switzerland, we rely on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where the provider is certified, or otherwise on the European Commission's Standard Contractual Clauses.
7. How long we keep data
| Data | How long |
|---|---|
| Data on your device | Until you delete it. Profile › Manage Data › Reset App Data deletes it; deleting the app removes it too. |
| Usage statistics | 2 months (our Google Analytics retention setting) |
| Crash reports | 90 days |
| Support emails | 24 months after the request is closed |
8. Your rights
Depending on where you live, you have rights to access, correct, delete and receive a copy of your personal data, to restrict or object to its use, and to withdraw consent at any time.
Health data never leaves your device, so you control it directly through Apple Health and the app. For usage statistics, crash reports or anything else, email admin@adept-labs.com. Usage data is linked only to random app identifiers, so we may ask for details that help us find it. We reply within one month, or within 45 days for US state requests.
You can also complain to your data protection authority, for example the authority in your EU country or the UK Information Commissioner's Office.
US residents (including California): in the last 12 months we have collected identifiers (random app identifiers), internet or other electronic network activity (app usage and diagnostics), approximate location derived from IP, and commercial information (which subscription was purchased). We do not sell or share personal information as defined by the CCPA/CPRA, and we don't use sensitive personal information to infer characteristics.
9. Children
PulseDNA Coach is not directed at children under 13, or under 16 in the EU/UK, and we don't knowingly collect their personal data. If you believe a child has given us personal data, contact us and we will delete it.
10. Security
On-device data uses iOS data protection. Connections to Firebase use HTTPS. No system is perfectly secure, so keep your device passcode and Apple Account safe.
11. Not a medical device
PulseDNA Coach is a wellness app. It does not diagnose, treat or prevent any disease and is not a substitute for professional medical advice.
12. Changes
We'll update this policy when the app or the law changes, and change the effective date above. If a change is significant, we will tell you in the app before it applies.
13. Contact
Adept Labs Technology Company Limited, Phu Tho Province, Vietnam, admin@adept-labs.com